### Enclosure 1

Page 1 of 13 

## EPA Information Collection Request for Nitric Acid NSPS (Subpart G)

Plant Data

Facility name JR Simplot Company Helm Plant

Facility owner (ultimate parent owner) JR Simplot Company

Plant Location

- Address 12688 South Colorado Avenue

Latitude/Longitude for Plant 36.54944/

- 120.112222

Describe location of latitude/longitude Center of Facility

City, State, ZIP code Helm, CA 93627

Year plant began operation October 1980

Information for Each Nitric Acid Production Line

(change names as needed and use the same names in the Excel spreadsheet)

Line 1 Line 2 Line 3

Year line began operation October 1980

Production Rate (Tons/Day of

100% Acid) 231 tons per day

Production Rate Range (Tons/Day of

100% Acid) 190

- 280

Subject to Subpart G? yes

Process Type ( high/low pressure) low

Oxidation pressure (psia) 100

- 110 lbs

Absorption pressure (psia) Design = 120 psia

Operation = 105 psia

% Acid strength Typically Produced 57%

Operating Hour s /Year Line 1 Line 2 Line 3

2008 8 400

2007 7546

2006 782 3

Control Technology

(list as many as applicable) NSCR

% Control Efficiency (based on most

recent compliance test) Line 1 Line 2 Line 3

NO X >99%

NO not available

NO 2 not available

### EPA Information Collection Request for Nitr ic Acid NSPS (Subpart G)

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Page 2 of 13 Permit Limits for Each Nitric Acid Production Line

(F ill in all applicable rows)

Line 1 Line 2 Line 3

NO X Emissions (tpy) n/a

NO X Emissions (lb/hr) 180 ppm 3 hr average

NO X Emissions (lb/ton of 100%

acid) n/a

Permitted NO X control efficiency, if

applicable n/a

If your permit includes limits for

other pollutants, please include as

much detail as possible below: Line 1 Line 2 Line 3

particulate matter emissions Not > 0.1 Grains/scf

Sulf u r not >

. 02% b y

v o lume, 2000 ppmv,

on dry basis averaged

over 15 consecutive

minutes

Gases discharged not > 10% opacity

Visible emissions Based on 10% opacity

### EPA Information Collection Request for Nitr ic Acid NSPS (Subpart G)

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Page 3 of 13 

## For each control device, please provide the key design parameters

Extended Absorption (Nitric Acid Production Line Name )

Length Approximately 65'

Design Information

(gal/ 10 3 acfm, etc) 50

- 60 g pm Nitric Acid produced

3750

- 3900 scf bleach air

Operation and Maintenance required

(Last 10 years) Tube Cleaning, leak repair, hose replacement.

Year absorption capacity was added n/a

If you use an additive in your absorption column:

Name of additive (i.e., hydrogen

peroxide) n/a

Concentration of additive (%): n/a

Explain the process:

Addition rate (gallons per hour): n/a

Ratio of additive to water: n/a

### EPA Information Collection Request for Nitr ic Acid NSPS (Subpart G)

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Page 4 of 13 SCR (Nitric Acid Production Line Name )

Type of Catalyst N/A use of NSCR

Is Catalyst New or Regenerated?

Catalyst Life (Design/Actual)

Catalyst Volume (m 3 )

Flow rate (scfm)

Ammonia injection rate (lb/hr)

Operation and Maintenance required

(Last 10 years)

Year began operation

### EPA Information Collection Request for Nitr ic Acid NSPS (Subpart G)

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Page 5 of 13 

## For each control device, please provide the key design parameters

NSCR (Nitric Acid Production Line Name )

Reductant used (methane, H 2 , etc) Butane

Rate of reductant used 75

- 85 scfm butane

Type of catalyst The catlyst in operation is multi component precious metal catalyst.

Precous metals used are Pd, Pt and Rh

Catalyst Volume (m 3 ) 35 ft 3

Flow rate (scfm) 22,000

Is Catalyst New or Regenerated? new

Catalyst Life (Design/Actual) guarantee is for one year. Anticpated life is 4

- 6 years.

Operation and Maintenance required

(Last 10 years) Spent catlyst replacement

Year began operation 1980

### EPA Information Collection Request for Nitr ic Acid NSPS (Subpart G)

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Page 6 of 13 

## Cost Information by Control Technology

Production Line Pollutant

Controlled Control

Technology Capital

(Yr of Cost basis) Annual O & M

(Yr of cost basis)

Nitric Acid NOx NSCR $450,000

(Replacement

estimates 2010) $1,025,000 (Budget

2010)



### Please provide additional cost in formation, comments, or notes below:

Replacement costs, at today metals prices for the Abatement catalyst would be $221,117.00, with 6

- 8

week delievery.

Replacement costs of Catalyst, butane used/year, mainteance = 24 hour remove and install basket, 8 hr

replace catalyst

The cost of butane has rapidly increased over the past year and accounts for the majority of our O&M

budget for this equipment

### EPA Information Collection Request for Nitr ic Acid NSPS (Subpart G)

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Page 7 of 13

### EPA Information Collection Request for Nitr ic Acid NSPS (Subpart G)

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Page 8 of 13 

## Continuous Emission Monitoring Systems

CEMS Information

Plant CEMS data recorded

concurrent with test runs (i.e.,

concentration, etc.). NOx concentration

CEMS Manufacturer Rosemont Analytical

CEMS Model Number Model 951 A

Description of sample extraction and

conditioning or dew point

maintenance systems 

### Sample is drawn from stack through a heated probe

assembly. Basic parts of this assembly are probe,

ceramic filter and heater.

Sample travels from probe through heated sample

line to inlet of primary exchanger of chiller.

Sample travels from discharge of primary exchanger

through vacuum gauge to suction side of vacuum

pump.

Sample is pushed out of discharge side of vacuum

pump, through pressure gauge, to inlet side of

secondary exchanger of chiller.

Sample continues from discharge of secondary

exchan ger to inlet of Zeks coalescing filters, 2ea ch

, and from discharge of filters to inlet of NH3

scrubbers, 2ea ch

.

Ability to distinguish between NO

and NO 2 ? No

I dentify all periods of startup,

s hutdown, and malfunction,

regardless of whether the event

caused an exceedence (during the

past 3 years)

DATE time interval

2/7/2006 18 Hrs 20 mins

4/11/2006 25 Hrs 20 mins

5/18/2006 9 Hrs 30 mins

### EPA Information Collection Request for Nitr ic Acid NSPS (Subpart G)

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Page 9 of 13 6/8/2006 22 Hrs

6/10/2006 9 Hrs 30 mins

6/25/2006 6 Hrs 30 mins

6/25/2006 83 Hrs

7/23/2006 27 Hrs

8/14/2006 43 Hrs

10/16/06 thru 11/11/06 27Days & 2 hrs

01/13/07 thru 01/17/2007 3 Days & 16 Hrs

3/20/2007 25 Hrs

04/21/07 thru 04/22/2007 15 Hrs

05/14/07 thru 05/15/2007 23 Hrs

06/08/07 thru 06/09/2007 13 Hrs

06/23/07 thru 06/24/2007 21 Hrs

06/24/07 thru 06/25/2007 7 Hrs

7/5/2007 6 Hrs

07/13/07 thru 07/14/2007 24 Hrs

09/25/07 thru 09/27/2007 13 Hrs

06/23/07 thru 06/24/2007 58 Hrs

09/28/07 thru 09/30/2007 96 Hrs

10/01/2007 THRU 10/28/2007 28 Days

11/10/2007 18 Hrs

11/11/2007 THRU 11/15/2007 4 Days

11/16/2007 20 Hrs

01/28/08 thru 01/30/08 43 Hrs

2/5/2008 12 Hrs

04/07/08 thru 04/09/08 46.4 Hrs

04/13/08 thru 04/14/08 14..2 Hrs

05/03/08 thru 05/05/08 43.1 Hrs

6/17/2008 22.4 Hrs

8/20/2008 6 Hrs

08/26/08 thru 08/27/08 25 Hrs

10/26/08 thru 10/27/08 35 Hrs

### EPA Information Collection Request for Nitr ic Acid NSPS (Subpart G)

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Page 10 of 13 11/11/08 thru 11/13/08 69 Hrs

11/24/08 thru 11/25/08 29 Hrs

12/18/08 thru 12/20/08 57 Hrs



### 2/14/2009 4 hours 30 mins

3/10/2009 9 hrs

3/23/2009 4 hrs 12 mins



### 2/9/2009 thru 2/12/2009 36 hrs

3/10/2009 thru 3/11/2009 4 hrs 10 mins

3/23/2009 thru 3/24/2009 3 hrs 18 mins

4/20/2009 thru 4/23/2009 72 hrs



### 2/14/2009 62 hrs 35 mins

3/10/2009 18 hrs 53 mins

7/10/2009 thru 7/13/2009 62 hrs 35 mins

7/13/2009 thru 7/15/2009 18 hrs 53 mins

10/09/2009 thru 10/20/09 24 hrs

10/23/2009 3 hrs

10/23/2009 5 hrs

10/23/2009 1 hr 15 mins

10/25/2009 21 hrs 25 mins

10/26/2009 thru 10/27/2009 23 hrs 42 mins

10/28/2009 13 min

1/11/2010 thru 1/14/2010 35 hrs 49 min

1/13/2010 5 hrs 49 mins.

2/22/2010 10 hrs 36 mins.

Capital costs $49,894 equipment

Operation and Maintenance costs Operations costs per year = $11,700 Maintenance costs (man hrs) =

$1,567

Cost of quarterly audits Annual tests $10,950

Year began operation 1980

CEMS Data (Monthly and Annual)



### Include m onthly and a nnual NO X 

### CEMS data for the last 3 years. Please submit the CEMS

data electronically

. (SEE ATTACHED DATA)

### EPA Information Collection Request for Nitr ic Acid NSPS (Subpart G)

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Page 11 of 13 

## General Discussion

1. Please provide your thoughts on trends in nitric acid production as far as type of process that

is used; types of absorber used, trends in selecting control devices , improvements in control

efficiency in existing control devices, energy efficiency

.

We ha ve not identified a more cost

- effective way to reduce our emissions, but continue to

investigate new technologies and evaluate the cost

- benefits of each

.

2. Please describe your thoughts on the air pollution controls that are used at your facility such

as reliability, O&M costs including energy penalty , etc.

The largest cost of our current control method is the required Butane. The cost off Butane has

increased sharply in the last year and is the primary cost associated with operating the NSCR.

3

. Please provide recommendations on the revisions you would like to see in this NSPS.

40 CFR 60.73 specifies a span value of 500 ppm for the Continuous NOx Emission Monitor. At this

value, the span value is very high compared to the normal operating range of about 10

- 20 ppm. During

an upset situation, 500 ppm is very low compared to spikes in the range of 3000 ppm. A variable span

range would ensure accuracy of the instrument over the range the instrument measures.

40 CFR 60 Appendix B is applicable for sources using stack tests as the method of demonstrating

compliance. 40 CFR 60 Appendix F applies at sources where Continuous Emission Monitors are used to

demonstrate compliance. This needs to be clearly stated in the regulations as we h ave seen agencies

misinterpret the applicability of Appendix F. We have seen instances where EPA has provided written

clarification and guidance, but it needs to be reflected in actual rule as well.

It is not possible to comply with existing emission and opacity limits during periods of startup, shutdown,

and malfunction. Therefore, it is important to clarify within Subpart G that the emission standards do not

apply during these periods. An alternate approach would be to create a separate considerably h igher

emission limit for these periods.

### EPA Information Collection Request for Nitr ic Acid NSPS (Subpart G)

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Page 12 of 13 

## Startup, Shutdown, and Malfunction

1. Please describe the maximum emission levels of NO X 

### or NH 3 

### expected during a startup,

shutdown, and malfunction event.

The maximum emissions levels of NOx during s tatup, shutdown, and malfunction events are

greater than 2,500 ppm. Actual ppm is higher than what we are capable of measuring at this

time.

2. Please describe how long excess/elevated emissions NO X 

### or NH 3 

### will typically occur during

a startup, shutdown, and malfunction event.

The excess/elevated emissions of NO

x 

### could be less than 10 minutes to 1/2 hour during

shutdown, startup, and any malfunction events.

3. Please describe any equipment or work practices that are employed to minimize or eli minate

the quantity or duration of excess/elevated emissions of NO X 

### or NH 3 

### during startup,

shutdown, and malfunction event s.

During start

- up, we preheat the catalyst in the NSCR to reduce emissions. During all

evolutions, emissions are monitored closely to ensure prompt corrective action,

including shut

- down. During normal shutdown, the system is purged through the

absorber to prevent excess emissions. During a malfunction

- shutdown, there are no

controls , beyond the shutdown itself, to reduce emissions.

### EPA Information Collection Request for Nitr ic Acid NSPS (Subpart G)

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Page 13 of 13 

## Emission Testing

Note: Previous emission testing performed does not meet the prescribed methods below.

Testing is scheduled for April 7 and 8, 2010.

1. Include emissions testing conducted during t he last five years. Include tests for NO X 

### , and

NH 3 

### . Read and follow the guidance below.

2. Test method data of interest include those performed according to EPA Methods 7, 7A, 7B,

7C, 7D

, or Method 320.

3. Method 7E (for NO X 

### ) data can be submitted, but only if the testing was performed with the

following modifications for nitric acid plants. Because of the propensity of NO 2 

### to be

absorbed by water, the sampled gas must not contact any condensate, and the efficiency of

any NO 2 

### to NO converter (if needed by th e detection principle of the instrument) must be

determined and documented as described in the method. For wet basis measurement systems,

the tester must measure and report temperature data to show that the sample line and all

sample transport components u p to the inlet of the analyzer (and, for hot

- wet extractive

systems, also the analyzer) were maintained above the stack gas dew point. Use of a dilution

probe to reduce the dew point is an acceptable procedure, if documented. Section 8 of

Method 7E describ es the measurement system performance tests and documentation required

by the method, both prior to and following sampling. NO 2 

### calibration gas must be substituted

for NO calibration gas in the performance of system bias checks. The alternative mentioned

i n Section 8.6 to follow the dynamic spike procedure in Section 16.1 is acceptable, but only

with NO 2 

### spike gas. The dynamic spiking procedure is strongly recommended.

4. If you do not have emission test data for NO X 

### using a method in note 2 or using Method 7E

according to the modified protocol in note 3

, you must conduct a stack test to determine

NO X 

### emissions following one of the approved methods above.

5. If you do not have emission test data for NH 3 

### , you must conduct a stack test to determine

the emissions using the procedures of Method 320.

6. If a concentration is at or below the applicable method’s detection level, then provide

information about the method (title and source), the calculated detection level in units of the

applicable raw material or emissions concentration or mass rate, and the procedure for

determining the detection level.

7. Additional stack testing guidance is contained in Enclosure 7

.